Two-thirds of safety data sheets containing newly flagged hazardous substances have never been revised, according to the first systematic analysis of REACH Candidate List compliance behaviour
The chemical supply chain is taking an average of 20 months to update safety data sheets after the European Chemicals Agency officially designates a substance as being of very high concern, according to new research published by SDS Manager, a safety data sheet management platform with access to documents from more than 2,800 active commercial suppliers.
The study, which analysed 8,611 safety data sheets and substance combinations across Candidate List additions from the past five years, found that 61.6% of affected documents have never been revised since their substance was added to ECHA's Candidate List. Among the minority that were updated, the median delay between the official ECHA publication date and the document revision was 609 days.
Article 33 of the REACH Regulation requires suppliers of articles containing Substances of Very High Concern above a concentration of 0.1% by weight to communicate that information to downstream users without delay. The regulation does not specify a fixed number of days. The data suggests that in practice, "without delay" has meant nearly two years for those who respond at all, and nothing for the majority who do not.
"The legal obligation is clear," said Erlend Bruvik, Founder of SDS Manager. "What our data shows, for the first time with actual numbers, is that for the vast majority of affected documents, the required information never arrives. A 609-day median lag, with six out of ten safety data sheets never updated. That is not the picture that appears in regulatory impact assessments. It is the operational reality of REACH compliance as it actually exists."
The findings are consistent with ECHA's own enforcement data. The agency's REACH-EN-FORCE-6 project, which audited Article 33 compliance among article suppliers, found that only 5 of 45 audited articles met the business-to-business communication requirement, a non-compliance rate of approximately 89%. ECHA described the level of disclosure as "not acceptable."
The Scale of a Single Addition
The most recent Candidate List update, published on 4 February 2026, added 11 new substances including n-hexane, a common industrial solvent used in degreasers, adhesives, and cleaning products and classified as a neurotoxin linked to peripheral neuropathy in workers. The addition illustrates the scale of disruption a single designation can create.
In the SDS Manager database alone, 3,774 active safety data sheets from 1,360 distinct suppliers contain n-hexane. As of the study date, 97 days after the ECHA publication, only 40 of those documents, or 1.06%, had been revised. More than half of the unrevised documents were last updated over five years ago. The oldest revision in the dataset is dated 1979.
Test David N
David N is a passionate tech writer with over 8 years of experience covering emerging technologies, software development, and digital innovation. He enjoys making complex topics easy to understand.